The revised draft gives bronze a two-year reprieve, but not silver or gold. Regardless of the distinction between gold, silver and bronze, 7.1.3 should be optional, as it is too early to require this standard, for the following reasons:
1. Although human rights issues in the supply chain draw public attentions recent years, social auditing by a third party is not always accepted by small and medium-sized suppliers at the stage. It will take several years to have them understood the needs for social auditing and to establish an internal system to respond to the request of social audits from customers. In particular, it is very hard for small and medium-sized suppliers to accept the burden of audit costs (approximately US$10,000 per audit) in recent depression years. It also requires considerable efforts and labor for suppliers to prepare and complete a social audit from the opening, audit, remediation and closure. It takes more than one and a half years in some cases.
2. There is a concern that excellent small and medium-sized suppliers located in developing countries may be excluded from the supply chain only for a reason that they do not have enough capacity to respond to the social audit or they fail to correct audit non-conformities due to lack of resources. As a result, it would worsen the economic situation of developing countries and would cause poverty, forced labor, child labor and other human rights violations.
3. Unlike the ISO certification, the RBA head office has a right to select an audit firm for the VAP audit and controls scheduling of it. Therefore, manufacturer’s requests for the VAP audits for “which suppliers and when” are not necessarily accepted. As a result, there is a concern that manufacturers will not be able to meet this criterion.
4. It is unclear how manufacturers will evaluate Part A section. As shown in “References and details”, identification of actual tools of the ”RBA's risk assessment platform combined with the SAQ” is helpful. However, such tools are only available to the manufacturers having an RBA membership. Further, the RBA's risk assessment platform or SAQ is an independent tool, and we are not sure how the combination of these two tools will be worked out to determine the Part A risks of suppliers. When using the tool called “Risk SAQ” recently developed by the RBA, suppliers located in Asian countries systematically would have a higher risk score. Though many suppliers in Asia are trying to mitigate human rights risks, such suppliers also would move to the Part B regardless of their efforts just because they are located in Asia.
5. There are concerns from the perspective of the legal system for protecting SMEs in each country. When manufacturers reduce the load on small and medium-sized enterprises, for example, because Japan has a strict Small and Medium-sized Enterprise Protection Law, it may become an excessive burden for manufacturers to satisfy the standards legally, if manufacturer bears a lager burden of the suppliers.
